Towing companies have two pathways to Subchapter M compliance:

USCG Option

• Direct Coast Guard inspections verify your vessels meet certification requirements.

• Inspections are frequent, scheduled, and don’t always account for the specific nuances of your processes, which can impact operations.

• Multiple visits may be needed to resolve deficiencies, sometimes delaying vessel availability.

TSMS Option

• The Towing Safety Management System (TSMS) is a more flexible approach, rooted in ISM Code principles.

• Reduces Coast Guard time onboard and allows flexible inspection scheduling.

• TSMS is scalable, dynamic, and company-specific, improving safety and operational efficiency while reducing downtime.

• Supports complex towing operations by embedding your safety processes directly into your SMS.

Think of a TSMS not just as a compliance form, but as a living safety system, tailored by the company for your specific needs, that works with your crew, not against them.

The Coast Guard designed TSMS to align closely with the ISM Code, requiring vessels to address the purpose, objectives, functional requirements, and core elements of a Safety Management System (46 CFR Part 138, Subpart B). This ensures a globally recognized standard for vessel safety.

• ISM-compliant vessels are considered TSMS-compliant (46 CFR §138.225(a)).

• Your ISM Certificates, DOC, and SMC can serve as objective evidence of compliance.

• Some SMS updates may still be needed for Subchapter M-specific requirements, like hull surveys.

At Marinetegrity, we translate these regulations into real-world procedures that your crew can actually follow. Our former ABS auditors and surveyors—combined with experienced tug boat sailors—ensure that what’s on paper matches what happens onboard, whether you’re managing a tandem tow, performing hip up operations, or conducting routine maintenance.

We bridge the gap between “what the rules say” and “what actually works in practice.”

Internal audits are a cornerstone of a functional TSMS, ensuring your SMS is practical, effective, and truly implemented onboard. The USCG requires auditors to be independent from the procedures they evaluate (46 CFR §138.310(d)(3)), though smaller organizations may use qualified internal staff if independence is reasonably maintained.

At Marinetegrity, our Sub M internal audits are unlike typical text-book style audits:

• Conducted by auditors with real tug boat experience – we understand the operational realities of tow operations and daily vessel challenges.

• Tailored to your SMS framework – we don’t follow a fixed checklist; our audit questions are customized to your SMS, operations, and risk tolerances.

• Focused on practical compliance – our goal is to identify gaps, enhance operational safety, and prepare your fleet for TSMS or USCG inspections.

Unlike standard audits, our questions come from hands-on tug boat experience, ensuring your SMS isn’t just compliant on paper—it actually works in practice.

From large fleets to single-vessel towing operators, Marinetegrity delivers the compliance expertise, tools, and support maritime companies rely on every day.

• Expertise You Can Rely On: Former ABS auditors and surveyors with deep USCG Sub M and ISM experience.

• Operational Insight: Experienced tug boat sailors who understand tow operations and day-to-day challenges onboard.

• Bridge Between Paper and Practice: We translate Subchapter M and TSMS requirements into systems your crew can actually use.

• Proven Results: Successfully supported multiple towing companies in SMS development, internal audits, and full Sub M compliance.

• Tailored Solutions: Customized to your fleet, operations, and risk profile, maximizing safety and efficiency.

With Marinetegrity, your Towing Safety Management System (TSMS) isn’t just compliant—it’s practical, effective, and built for your operation.